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Data Analysis and Research for Trade Transparency System

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Overview Edit

ICE maintains the Data Analysis and Research for Trade Transparency System (DARTTS), which generates leads for and otherwise supports ICE investigations of trade-based money laundering, contraband smuggling, trade fraud, and other import-export crimes. DARTTS analyzes trade and financial data to identify statistically anomalous transactions that may warrant investigation. These anomalies are then independently confirmed and further investigated by experienced ICE investigators.

DARTTS is owned and operated by the ICE Trade Transparency Unit (TTU). Trade transparency is the concept of examining U.S. and foreign trade data to identify anomalies in patterns of trade. Such anomalies can indicate trade-based money laundering or other import-export crimes that ICE is responsible for investigating, such as contraband smuggling, trafficking of counterfeit goods, misclassification of goods, and the over- or under-valuation of goods to hide the proceeds of illegal activities. As part of the investigative process, ICE investigators and analysts must understand the relationships among importers, exporters, and the financing for a set of trade transactions, to determine which transactions are suspicious and warrant investigation. DARTTS is designed specifically to make this investigative process more efficient by automating the analysis and identification of anomalies for the investigator.

DARTTS allows ICE to perform research and analysis that is not available in any other system because of the data it contains and the level of detail at which the data can be analyzed. DARTTS does not seek to predict future behavior or “profile” individuals or entities (i.e., identify individuals or entities that meet a certain pattern of behavior that has been pre-determined to be suspect). Instead, it identifies trade and financial transactions that are statistically anomalous based on user-specified queries. Investigators follow up on the anomalous transactions to determine if they are in fact suspicious and warrant further investigation. Investigators gather additional facts, verify the accuracy of the DARTTS data, and use their judgment and experience in making that determination. Not all anomalies lead to formal investigations.

DARTTS is currently used by ICE Special Agents and Criminal Research Specialists who work on TTU investigations at ICE Headquarters or in the ICE field and foreign attaché offices, as well as properly cleared support personnel. In April 2010, ICE initiated the transition of DARTTS to the ICE enterprise network, making DARTTS available to a greater number of ICE agents in the field, subject to appropriate access controls. ICE is continuing to deploy the enterprise version throughout ICE.

Technology and methodology Edit

DARTTS uses trade data collected by CBP, other federal agencies and foreign governments, and financial data collected by CBP and FinCEN. DARTTS data is primarily related to international commercial trade and financial transactions. ICE does not collect information directly from individuals or entities for inclusion in DARTTS. Instead, ICE receives data from sources via CD-ROM, external storage devices, or electronic data transfer and loads the data into DARTTS. DARTTS uses COTS software to analyze raw trade and financial data to identify anomalies and other suspicious transactions. The software application is designed for experienced investigators. It enables the analysis of structured and unstructured data. It also allows non-technical users with investigative experience to analyze large quantities of data and rapidly identify problem areas. The program makes it easier for investigators to apply their specific knowledge and expertise to complex sets of data.

DARTTS performs three main types of analysis. It conducts international trade discrepancy analysis by comparing U.S. and foreign import and export data to identify anomalies and discrepancies that warrant further investigation for potential fraud or other illegal activity. It performs unit price analysis by analyzing trade pricing data to identify over- or under-pricing of goods, which may be an indicator of trade-based money laundering. DARTTS also performs financial data analysis by analyzing financial reporting data (the import and export of currency, deposits of currency in financial institutions, reports of suspicious financial activities, and the identities of parties to these transactions) to identify patterns of activity that may indicate money laundering schemes.

DARTTS routinely receives bulk financial and trade information collected by other agencies and foreign governments, hereafter referred to as “raw data.” The agencies that provide DARTTS with trade data collect any PII directly from individuals or enterprises completing import-export electronic or paper forms. The agencies that provide DARTTS with financial data receive PII from individuals and institutions, such as banks, that are required to complete certain financial reporting forms. The PII in the raw data is necessary to link related transactions together. It is also necessary to identify the persons or entities that should be investigated further.

ICE investigators with experience conducting financial, money laundering, and trade fraud investigations use the completed analysis to identify possible criminal activity and provide support to field investigators. TTU investigators at ICE Headquarters refer the results of DARTTS analyses to ICE field offices as part of an investigative referral package to initiate or support a criminal investigation. ICE investigators in the domestic field offices can also independently generate leads and subsequent investigations using DARTTS analysis. In addition, ICE investigators in attaché offices at U.S. embassies abroad have access to DARTTS on standalone terminals. These investigators use DARTTS to conduct analyses in support of financial, money laundering, and trade fraud investigations, and to respond to inquiries from partner-country TTUs with whom ICE shares anonymized U.S. trade data.

Data sources Edit

All of the raw data in DARTTS is provided by other U.S. agencies and foreign governments, and is divided into three broad categories: U.S. trade data, foreign trade data, and U.S. financial data. The U.S. trade data in DARTTS is (1) import data in the form of an extract from the ACS, which CBP collects from individuals and entities importing merchandise into the United States who complete CBP Form 7501 (Entry Summary) or provide electronic manifest information via ACS, (2) export data that CBP and the U.S. Department of Commerce collect from individuals and entities exporting commodities from the U.S. using Commerce Department Form 7525-V (Shipper’s Export Declaration) or through AES, and (3) publicly available aggregated U.S. export data (i.e., data that does not include PII) purchased by ICE from the U.S. Department of Commerce.

In the DARTTS enterprise version, ICE plans to incorporate a new data module with bill of lading data, which is data provided by carriers to confirm the receipt and transportation of on-boarded cargo to a specified destination. This information includes consignee name and address, shipper name and address, container number, carrier, and bill of lading. It is collected by CBP via the AMS, and is provided to ICE through CD-ROM, external storage devices, or electronic data transfers for uploading into DARTTS. ICE updated the DARTTS PIA to include the new bill of lading module.

The foreign import and export data in DARTTS is provided to ICE by partner countries pursuant to a Customs Mutual Assistance Agreement (CMAA) or other similar agreement. Certain countries provide trade data that has been stripped of PII. Other countries provide complete trade data, which includes any individuals' names and other identifying information that may be contained in the trade records.

ICE receives U.S. financial data from FinCEN for uploading into DARTTS. This data is in the form of the following financial transaction reports: CMIRs (declarations of currency or monetary instruments in excess of $10,000 made by persons coming into or leaving the United States); Currency Transaction Reports (deposits or withdrawals of $10,000 or more in currency into or from depository institutions and casinos and card clubs); Suspicious Activity Reports (information regarding suspicious financial transactions within depository institutions, money services businesses, the securities and futures industry, and casinos and card clubs); Reports of Cash Payments over $10,000 Received in a Trade or Business (reports of merchandise purchased with $10,000 or more in currency); and FBAR data (reports of financial interest in foreign financial accounts in excess of $10,000).

DARTTS itself is the source of analyses of the raw data produced using COTS software analytical tools within the system. In addition, DARTTS creates extracts of U.S. trade data that has been stripped of PII, and provides those extracts to partner countries that operate their own TTUs and with whom the United States has entered into a CMAA or other similar agreement. The U.S. financial data in DARTTS is not shared with partner countries.

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